Weeks After Issuing Sanctions Licenses, U.N. Launches Appeal for Afghanistan and U.S. Steps Up Aid Pledge

The licenses expand authorized activity in Afghanistan by nongovernmental organizations, a law firm said 

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By Samuel Rubenfeld

Tuesday, January 11, 2022


The United Nations on Tuesday launched an appeal for more than USD 5 billion of funding for Afghanistan, its largest ever for a single country, amid a collapse in basic services since the Taliban took control last summer.

Half of the Afghan population faces acute hunger, with more than 9 million people displaced, according to the U.N. Office for the Coordination of Humanitarian Affairs. The scale of the need is already enormous and, if insufficient action is taken now, U.N. officials said they’ll ask for double – USD 10 billion – next year. 

To address the need, the U.S. announced a contribution of more than USD 308 million in humanitarian assistance to the people of Afghanistan, bringing U.S. aid in the country and to Afghan refugees to nearly USD 782 million since October 2021. The U.S. is also donating another 1 million COVID-19 vaccines through COVAX, bringing its total to 4.3 million.

The appeal and U.S. contribution come weeks after U.N. human rights groups had called on the international community to clear the way for aid to enter the country and prevent humanitarian disaster. The U.N. Security Council adopted a resolution late last year that carved out an exemption in the international sanctions program for humanitarian aid to reach Afghanistan. 

The resolution allows for the processing and payment of funds while urging providers to use “reasonable efforts” to minimize the accrual of benefits to those on the U.N. sanctions list.

The U.S. also issued an additional three general licenses late last year to facilitate the flow of aid and other support to the Afghan people, and issued a fact sheet consolidating the relevant authorizations and guidance for providing such assistance. 

The moves followed engagement with nongovernmental organizations (NGOs) operating in Afghanistan by Deputy Treasury Secretary Wally Adeyemo. "The U.S. is the largest single provider of humanitarian assistance in Afghanistan. We are committed to supporting the people of Afghanistan, which is why [the] Treasury is taking these additional steps to facilitate assistance,” Adeyemo said at the time.

The new licenses allow transactions involving the Taliban or the Haqqani Network, both of which are under U.S. sanctions, for the conduct of official business by the U.S. government, certain international organizations and NGOs, subject to certain conditions. 

The licenses don’t authorize any debit to a blocked account on the books of a U.S. financial institution, according to guidance issued by the U.S. Treasury Department. They also don’t allow transfers to the Taliban, the Haqqani Network or any entity in which they hold a majority stake other than for paying taxes, fees, import duties or to buy permits, the guidance said. 

There are also numerous other individuals and entities operating in Afghanistan that are under U.S. sanctions but are not covered by any licenses, meaning transactions with them remain prohibited, according to the Treasury’s guidance.

The latest licenses also follow authorizations issued last fall by the Treasury concerning humanitarian transactions and exports of agricultural commodities, medicine and medical devices, Kharon reported at the time. And in early December, the Treasury allowed personal remittances to Afghanistan that would otherwise be prohibited by U.S. sanctions regulations.

“In comparison to earlier authorizations, the new [licenses] significantly expand the permissible activities that can be undertaken in Afghanistan by the U.S. government, the United Nations, NGOs and various other international organizations named in the [licenses],” the law firm Steptoe & Johnson LLP said in a recent note to clients. 

“The new [licenses] should enable NGOs and other organizations to undertake a wider range of activities that are not clearly authorized under [the license issued in the fall],” the note said.

The aid package announced Tuesday includes food and nutrition assistance; support for health care facilities and mobile health teams; and winterization programs—including the provision of emergency cash grants, shelter kits, heaters, blankets, and warm clothing, the U.S. Agency for International Development (USAID) said in a statement. For the aid to be most effective, workers, especially women, must be able to operate independently and securely, USAID said.

“The new contribution from the U.S. will provide life-saving aid for the most vulnerable, to include women, girls, minority populations and people with disabilities,” USAID said.

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